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DOGGETT v. COMMISSIONER

Docket Nos. 9106-72, 9074-75.

66 T.C. 101 (1976)

I. E. DOGGETT AND OVATER K. DOGGETT, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 15, 1976.

Attorney(s) appearing for the Case

Daniel R. Dixon, for the petitioners.

Gary F. Walker, for the respondent.

OPINION

SIMPSON, Judge:

This matter arises because the Commissioner has issued two notices of deficiency with respect to the same transaction. In a notice of deficiency dated September 19, 1972 (the first notice), he determined a deficiency of $13,226.41 in the petitioners' income tax for 1969. Such deficiency was based upon a finding that they realized long-term capital gain in that year of $70,387.57 from the sale of stock in the Yellow Cab Co....

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